Our Commitment

FlexSpace Logistics Inc. (“we”) respects your right to privacy and will not sell or share any personal information you provide us with any third party unless you give us prior consent and except as set forth in this policy. Your privacy is protected in all interactions with our company including while you are using, our website at www.flexspacelogistics.com, and/or communicating with our call center. Your ability to make informed choices about the uses of your information is important to us.

To earn and maintain your trust we have designed our privacy policy to meet or exceed the requirements of Canadian federal and provincial legislation regarding the collection, use and disclosure of personal information.

Scope

This policy applies to personal information we collect through our call center, our storage locations, and our website at www.flexspacelogistics.com.

Accountability

We have designated a Privacy Officer who is accountable for our compliance with this privacy policy. The Privacy Officer’s contact information is below.

Purposes

When collecting personal information, we will state the purpose of collection and will provide, on request, contact information for the Privacy Officer who can answer questions about the collection.

We may collect various types of information from you, including your name, address, telephone number, e-mail address, product purchase intentions, your interaction with our website (including information such as IP addresses, internet service provider, browser type, language, access times, referring website, etc.) and other information you provide to us.

We collect, use and disclose your personal information for the following purposes:

• to process your requests, to provide you the highest quality of service and to understand your needs so that we can serve you better - for example, we may use your e-mail or postal address to alert you about pricing details or new features of the program;
• to enable participating FlexSpace Logistics locations to provide you with the products or services you order, as well as information regarding offers, promotions, and news relating to participating FlexSpace Logistics locations;
• to compile aggregate statistics about the total number of daily visitors to our websites, the pages most frequently visited and how long people stay at each page, which in turn allows us to understand our customers’ needs and to develop products and services to serve those needs;
• to confirm your identity; and
• to comply with legal and regulatory requirements.

Personal information about our customers may be processed and stored in Canada and the United States, or any other country in which our service providers maintain facilities, and your personal information may be subject to applicable disclosure laws in those jurisdictions, which may result in that information becoming accessible to law enforcement and national security authorities of those jurisdictions.

When your personal information is to be used for a purpose not previously identified, the new purpose will be disclosed to you prior to such use, and your consent will be sought unless the use is authorized or required by law.

Except as described in this policy, we will not disclose your personal information to third parties without your consent other than to participating Access Storage locations, our service providers for the purposes described under the heading “Limits on Using, Disclosing and Retaining Personal Information”.

We occasionally hire other companies to provide services on our behalf, such as hosting websites. Those service providers will be permitted to obtain only the personal information they need to deliver the service in question, and our contract with them will require them to maintain the confidentiality of that information.

Consent

You have the choice of whether or not to give us your personal information. If you share your personal information, we will tell you why we are collecting it. By providing us your personal information, you agree to our using it for the purposes stated. In certain places or certain pages on our website, we will ask you specifically if you wish to receive further information or to be contacted by us or a FlexSpace Logistics representative in the future. At that time, we will note and abide by your preference.

At any time, subject to legal restrictions, you may withdraw or change your consent to our use of your information, request us to delete it from our files, or notify us if you do not wish us to use your information for any purpose other than for the purposes specifically identified when you provided it to us (See Contact Us, below). Information collected through cookies and pixel tax may not be optional. We will inform you of the implications of withdrawing your consent.

Limits on Collection

We will not collect information indiscriminately and will limit collection of information to that which is reasonable and necessary for the above purposes.

Limits on Using, Disclosing and Retaining Personal Information

We will only use and disclose your personal information for the purposes set out above and as authorized by law. We will keep personal information used to make a decision affecting you for at least one year after using it to make the decision, unless otherwise permitted or required by law.

We will destroy, erase or make anonymous documents or other records containing personal information as soon as it is reasonable to conclude that the original purpose is no longer being served by retention of the information and retention is no longer necessary for legal or business purposes. We will take due care when destroying personal information so as to prevent unauthorized access to the information.

Accuracy

We will make a reasonable effort to ensure that personal information we are using or disclosing is accurate and complete. In some cases, we rely on you to ensure that certain information, such as your address or telephone number, is current, complete and accurate.

If you demonstrate the inaccuracy or incompleteness of personal information, we will amend the information as required. If appropriate, we will send the amended information to third parties to whom the information has been disclosed.

When a challenge regarding the accuracy of personal information is not resolved to your satisfaction, we will annotate the personal information under our control with a note that the correction was requested but not made.

Safeguards

We protect the personal information in our custody or control by making reasonable security arrangements to prevent unauthorized access, collection, use, disclosure, copying, modification, disposal or similar risks.

We will take reasonable steps, through contractual or other reasonable means, to ensure that a comparable level of personal information protection is implemented by the FlexSpace Logistics locations and service providers who assist in providing services to you.

Confidentiality and security are not assured when information is transmitted electronically.

Providing Access

Upon written request and authentication of identity, we will provide you with your personal information under our control, information about the ways in which that information is being used and a description of the individuals and organizations to whom that information has been disclosed. We will make the information available within thirty days or provide written notice where additional time is required to fulfill the request.

In some situations we may not be able to provide access to certain personal information. This may be the case where, for example, disclosure would reveal personal information about another individual, the personal information is protected by solicitor/client privilege, the information was collected for the purpose of an investigation or where disclosure of the information would reveal confidential commercial information that, if disclosed, could harm our competitive position. We may also be prevented by law from providing access to certain personal information.

Where an access request is refused, we will notify you in writing, document the reasons for refusal and outline further steps which are available to you.

Employee Provisions

At FlexSpace Logistics we require that employees and team members protect the confidentiality of information about employees and our clients. This information includes, among other information, personnel files, contract records and product selection information.

Employees and users must follow the provisions of this Policy to 1) Prevent the disclosure of non-public information about our clients 2) Apply, where necessary, the appropriate protective measures required by the laws or regulations of those countries in which we are operating and 3) Support privacy requirements placed on FlexSpace Logistics in our dealings with our clients.

At FlexSpace Logistics, we prohibit non-job-related uses of software and business equipment, including but not limited to internet use, email, fax machines, printers, computers and copy machines.

Employees, who violate any part of this privacy policy, may be subject to discipline, up to and including termination of employment. Upon termination of employment for any reason, employees are required to immediately return all copies of all documents, electronic or digital media in their possession, which contain confidential information of FlexSpace Logistics Inc.

In the event of a breach of our privacy policy, we will notify you immediately.

Contact Us

If you have any concerns regarding our compliance with this policy or with applicable federal and provincial legislation you may address those concerns to our Privacy Office at the address provided below. Complaints concerning your personal information are taken seriously and all complaints are investigated.

Any inquiries, complaints or questions regarding this privacy policy should be directed in writing to our Privacy Officer as follows:

Iqbal Khan, Privacy Officer
FlexSpace Logistics Inc.
100 Canadian Rd
Toronto, Ontario
M1R 4Z5